ML19290E262
| ML19290E262 | |
| Person / Time | |
|---|---|
| Issue date: | 02/14/1980 |
| From: | Kerr G NRC OFFICE OF STATE PROGRAMS (OSP) |
| To: | Taylor A FLORIDA, STATE OF |
| Shared Package | |
| ML19290E263 | List: |
| References | |
| NUDOCS 8003100044 | |
| Download: ML19290E262 (4) | |
Text
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UNITED JTATtiS y[f g#(
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Ref: SA/ECA Alvin J. Taylor Deputy Secretary Department of Health &
Rehabilitative Services 1317 Winewood Boulevard Tallahassee, Florida 32301
Dear Mr. Taylor:
Thank you for your letter of January 21, 1980 describing the actions which have been taken by the State of Florida to improve its regulatory program for agreement materials.
We believe the approval of the reclassification package, reassignment of certain personnel to perform inspections, and obtaining funding for five additional inspectors should go far in increasing the level of inspection effort and improving the quality of inspections.
Based on these actions, the staff believes the Florida program for regulation of agreement caterials is adequate to protect the public health and safety and compatible with the Comissioa's program. We do expect, however, to conduct our next full review of the Florida program in April,1980.
Based on your reply, it appears there is some misunderstanding of the comments made in our October 15, 1979 letter regarding the Scott Luminous inspection. A more detailed discussion of our recommendations is snown in the Enclosure.
I appreciate the personal efforts made by yourself and other management officials in taking the steps you have described.
I am sure you are aware that such efforts are necessary to address such problems as staffing and which had become. chronic in the Florida program.
I would like to meet with you in the near future to discuss in some detail the NRC's Agreement State program and explore some means which might be used by the State to avoid such problems in the future.
I will 80031000 W
Alvin J. Taylor contact you shortly to arrange a mutually convenient time for such a meeting.
Sincerely,
.(L) f G. Wayne err, Acting Director Office of State Programs
Enclosure:
As stated cc:
U. Clark, w/ encl.
NRC Public Document Room )
State Public Document Room) w/ encl. & ltr of 1/21/80
Enclosure COMMENTS ON SCOTT LUMIN0US, INC. INSPECTION 1.
License condition 7.B. of License No. 863-1, at the time of the July 10, 1979 inspection, authorized " Promethium-147 microspheres in luminous paint (emphasis added)...." The report stated "The promethium-147 is purchased from 3M Company as microspheres....."
The report also states, "In order to make the radioluminous paint used on hands and dials, the promethium is reduced to a concentration of.... " See Section E of the report.
We believe the licensee should have been held in noncompliance with License Condition 7.B. for receiving and possessing promethium-147 as microspheres, a form not authorized by the license.
We agree that rewording of the license to authorize the possession of promethium-147 in the form of microspheres would be appropriate if the licensee's procedures for handling the material in this form are adequate and approved by the State's licensing staff.
2.
Our comment regarding bioassays was limited to the fact that the report did not mention the licensee's bioassay program concerning License Condit' ion 14.A.
Condition 14.A. states, " Promethium-147 shall not be used in such a manner as to cause any individual to receive a radiation exposure such that combined urinary-fecal excretion rates exceed 2 microcuries per liter when averaged over a 90-day. collection period."
The only mention in the report regarding bioassays had to do with Condition 14.B which concerns a bioassay study on one representative employee.
We believe the rewording of Condition 14 would clarify this matter.
In response to Mr. Clark's request dated November 5, 1979, on January 22, 1980 we sent him detailed information on bioassay procedures, effluent monitoring and other related technical information.
3.
We commented that the report did not mention the licensee's methods for controlling or monitoring effluents to unrestricted areas.
These areas are those in which the licensee does not or cannot control, for purposes of radiation safety, such as the public domain outside his facility.
Section G of the inspection report relates to evaluation of contamination and airborne activity in work areas (restricted areas).
The report did not address efflue7t releases to unrestricted areas.
4.
We believe it inappropriate to issue a citation to a licensee against a situation or condition that might possibly occur, but does not, in fact, exist at the time such as an unposted radiation area which could exist.
A more appropriate citation would be the failure of the licensee to perform adequate surveys to determine the need for the posting of a
" Radiation Area" sign.
. 2-5.
It is standard practice for a regulatory agency to require a licensee to respond to an enforcement letter to allow the regulatory agency to assess the adequacy of the licensee's proposed corrective actions. We agree that follow-up visits are appropriate to determine the status of such corrective actions and the extent to which the licensee is complying with the coninitted requirements.
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